THIS NOTE EXPLORES THE BASIS AND IMPORT OF GORDON AND CONTRASTS ITS JUDICIALLY IMPOSED REQUIREMENT OF BAR ADMISSION FOR CRIMINAL TRIAL JUDGES WITH THE SOLUTIONS ATTEMPTED BY VARIOUS STATE LEGISLATURES TO GUARANTEE THE JUDICIAL COMPETENCE OF LOWER COURT JUDGES. OTHER ALTERNATIVES IDENTIFIED INCLUDE RESTRICTING THE CRIMINAL JURISDICTION OF THE LAY JUDGE, PROVIDING FOR TRANSFER OF PROCEEDINGS AT THE DEFENDANT'S REQUEST OR REQUIRING THE DEFENDANT'S CONSENT TO TRIAL BY A LAY JUDGE, AND PROVIDING FOR TRIAL DE NOVO BEFORE AN ATTORNEY JUDGE ON APPEAL. THE COMPLETE ELIMINATION OF LAY JUDGES IS ALSO DISCUSSED. THE AUTHOR CONCLUDES THAT A COMPETENT JUDICIARY, AS PROVIDED FOR IN GORDON, IS NECESSARY TO INSURE A DEFENDANT'S RIGHT TO A FAIR TRIAL.